HomeMy WebLinkAbout07-2311JEANNE B. COSTOPOULOS, ESQUIRE
Attorney I.D. No. 68735
5000 Ritter Road, Suite 202
Mechanicsburg, PA 17055
Telephone No. (717) 221-0900
Attorney for Defendant
LISA MILLIGAN,
Plaintiff
VS.
GEOFFREY DUNKLE,
Defendant/Petitioner
THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. `
v 7- a3! I l u L
CIVIL ACTION - AT LAW
CUSTODY
COMPLAINT IN CUSTODY
AND NOW, comes Plaintiff, Lisa Milligan, by and through her attorney, Jeanne B.
Costopoulos, Esquire, and avers the following in support of this Complaint in Custody:
1. Plaintiff, Lisa Milligan, is an adult individual currently residing at 24 Farmhouse
Lane, Carlisle, Cumberland County, Pennsylvania, 17015.
2. Defendant, Geoffrey Dunkle, is an adult individual currently residing at 981
Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania, 17043.
3. There is one dependent child from the relationship of the parties, namely Olivia
Dunkle, born February 17, 2002, hereinafter referred to as the child.
4. The child was not born out of wedlock. The parties were divorced from each other
on July 7, 2004.
5. The child is presently in the custody of Plaintiff, who resides at 24 Farmhouse
Lane, Carlisle, Cumberland County, Pennsylvania, 17015.
6
7
During the past five (5) years, the child has resided with the following persons at
the following addresses:
Name
Plaintiff
Plaintiff's husband
Plaintiff's son (Seth)
Address
24 Farmhouse Lane
Carlisle, PA 17015
Dates
2/07 to present*
Plaintiff
Plaintiff's husband
Plaintiff's son (Seth)
Plaintiff's sister
24 Farmhouse Lane
Carlisle, PA 17015
Defendant 981 Hummel Avenue
Defendant's fiance (Erin) Lemoyne, PA 17043
Defendant's fiance's son (Tyler)
Plaintiff
Plaintiff's husband
Plaintiff s son
365 S. Middlesex Road
Carlisle, PA 17015
Plaintiff
Plaintiff's husband
Plaintiff's son
Plaintiff
Defendant
6585 Carlisle Pike
Mechanicsburg, PA 17050
981 Hummel Avenue
Lemoyne, PA 17043
12/06 to 2/07*
6/06 to present*
5/06 to 12/06
5/02 to 5/06
2/02 to 5/02
*Since June of 2006, the parties have alternated physical custody of the child such
that Father exercises custody of the child on alternating weekends from Friday
through Wednesday and alternating weekdays from Monday through Wednesday.
The result is that the parties each have the child overnight for 7 nights out of
every 14.
Plaintiff is the natural mother of the child and she currently resides at 24
Farmhouse Lane, Carlisle, Cumberland County, Pennsylvania, 17015. She is
married to her husband, Scott A. Milligan.
2
8. Defendant is the natural father of the child and he currently resides at 981
Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania, 17043. It is
Plaintiff's understanding that although Defendant is currently single, he is
scheduled to be married on April 21, 2007.
9. The relationship of Plaintiff to the child is that of natural mother. Plaintiff
currently resides with her husband, Scott A. Milligan, their son, Seth Milligan,
and the subject child.
10. The relationship of Defendant to the child is that of natural father. Defendant
currently resides with his fiance, Erin Sullivan, and her son, Tyler Sullivan.
11. Plaintiff has not participated as a party or a witness, or in any other capacity in
other litigation concerning the custody of the child in this or any other Court.
12. Plaintiff has no information of a custody proceeding concerning the child pending
in a court of this Commonwealth.
13. Plaintiff does not know of a person not a party to the proceedings who has
physical custody of the child or claims to have custody or visitation rights with
respect to the child.
14. The best interest and permanent welfare of the child will be served by granting
Plaintiff primary physical and shared legal custody of her daughter.
15. Each parent whose parental rights to the child have not been terminated and the
persons who have physical custody of the child have been named as parties to this
action.
3
WHEREFORE, Plaintiff, Lisa Milligan, respectfully requests this Honorable Court to
grant her primary physical and shared legal custody of her daughter.
Respectfully Submitted:
Date:
By:
ANNE B. COSTOPOUL., SQUIRE
Attorney I.D. No. 68735
5000 Ritter Road, Suite 202
Mechanicsburg, PA 17055
Telephone No. (717) 221-0900
V14 a 7 Attorney for Plaintiff
4
I
VERIFICATION
I, Lisa Milligan, hereby verify and state that the facts set forth in the foregoing document
are true and correct to the best of my information, knowledge and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn
verification to authorities.
Date:
Lisa Milligan
1
ell
V
R? /rpm` w s ? ??
U
LISA MILLIGAN IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
GEOFFREY DUNKLE
DEFENDANT
07-2311 CIVIL ACTION LAW
. IN CUSTODY
ORDER OF COURT
AND NOW, Thursday, April 26, 2007 upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. the conciliator,
at ^ 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, May 16, 2007 at 3:00 PM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/ John-1 Mangan, Jr., Esp.
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For infonnation about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
? i?IU?r ?> i L wJ :,'Hi JO
3^IdjO-CJ31 H
LISA MILLIGAN,
Plaintiff
vs.
GEOFFREY DUNKLE,
Defendant/Petitioner
THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: No. 07-2311
CIVIL ACTION - AT LAW
CUSTODY
AFFIDAVIT OF SERVICE
since:, , iat .r.i3 me dace and rinxe indicated oeiow i
personally hand-delivered upon the person whom I know to be Geoffrey Dunkle, Defendant above,
true and correct copies of the following documents:
1) Letter to Geoffrey Dunkle from Jeanne B. Costopoulos, Esquire, dated May 2, 2007.
2) Complaint in Custody, date-stamped April 20, 2007, with attached certified Order of
Court dated April 26, 2007, scheduling a Pre-Hearing Custody Conference before John
J. Mangan, Jr., Esquire, the Custody Conciliator, on Wednesday, May 16, 2007, at
3:00 p.m. on the 4t` floor of the Cumberland County Courthouse.
I further hereby swear and affirm that the above statement is true and correct and is made
subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities.
By: ,> U r,
,1! -
Signature
Name: F. Lv-C (N No
(Print name)
Address: i?, O , No. Y_ - _
?' ? ?rz rvtr, r?sbb,? r . ?. S '? o R a
Date: 5-, t; ' 6-7
Time: S : 4 1 P. fM
-? -:-? ?.
?- '
:-;;t
'=• r .
:? ,
? _?
?
cf?
LISA MILLIGAN,
Plaintiff
VS.
GEOFFREY DUNKLE,
Defendant/Petitioner
THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: No. 07-2311
CIVIL ACTION - AT LAW
CUSTODY
AFFIDAVIT OF SERVICE
xxn uTiuctS Yic?: tcT i}y lyili CS ii(Yl? SWW: .:14L 011 iJl Uaw and. tune indicaLed below 1
personally hand-delivered upon the person whom I know to be Geoffrey Dunkle, Defendant above,
true and correct copies of the following documents:
1) Letter to Geoffrey Dunkle from Jeanne B. Costopoulos, Esquire, dated May 2, 2007.
2) Complaint in Custody, date-stamped April 20, 2007, with attached certified Order of
Court dated April 26, 2007, scheduling a Pre-Hearing Custody Conference before John
J. Mangan, Jr., Esquire, the Custody Conciliator, on Wednesday, May 16, 2007, at
3:00 p.m. on the 4th floor of the Cumberland County Courthouse.
I further hereby swear and affirm that the above statement is true and correct and is made
subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities.
By: C? (U r,
.? _ .?
Signature
Name: _ `Q F. L c1-C t A No
(Print name)
Address: P'O NO
?
.?'? r?2?s nrs? ? r,?, c? o R n
Date: S c) - 677
Time: S• 4 1 R m
C7 ?
-.n z?
LISA MILLIGAN,
VS.
IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY,
PENNSYLVANIA
GEOFFREY DUNKLE,
Defendant
: NO. 07-2311
CIVIL ACTION
CUSTODY
PETITION FOR SPECIAL RELIEF
1. On April 20, 2007, the above captioned Plaintiff filed a Custody complaint.
2. A custody conference was held on May 16, 2007.
3. Both Plaintiff, Defendant and their Attorneys attended the conference.
4. The conciliator assigned to the conference was John J. Mangan, Jr.
5. On June 21, 2007, more then 1 month after the conference, the undersigned telephoned the
office of Attorney Mangan and asked that a report from the conference officer be produced.
6. To date (July 13, 2007) Attorney Mangan has not issued a conference report.
7. To date, no temporary Order has been entered by the Court.
8. At the May 16, 2007 custody conference Lisa Milligan made intentional misrepresentations
to the Conference officer that she and Geoffrey Dunkle shared physical custody of Olivia,
the parties' minor child.
9. Geoffrey Dunkle told the conference officer that he was the primary physical custodian of
Olivia.
10. At the conference, on more then one occasion, the undersigned asked the conference officer
to document in detail in his conference summary report the days Lisa Milligan was claiming
she picked Olivia up from daycare and the evenings she said she supposedly had Olivia.
11. The undersigned knew that what Lisa Milligan was telling the conference officer was not
what Geoffrey Dunkle was telling the undersigned the physical custody arrangement was
and the undersigned believed at the custody conference that what Lisa Milligan was saying
would conflict with information which the undersigned would later obtain from the daycare
facility after the custody conference.
12. For several weeks the undersigned has been in possession of records from the daycare
facility which prove conclusively that Lisa Milligan made false and material
misrepresentations to the conference officer as to when she had physical custody of Olivia.
13. By making false and material misrepresentations to the conference officer, Lisa Milligan
obtained a verbal recommendation from the conference officer that from the point of the
conference forward the parties should split physical custody of Olivia on a 50% - 50%
basis.
14. The parties have been following the recommendation of the conference Order even though
no Court Order has been issued to date implementing the 50% - 50% recommendation of
the conference officer in reference to physical custody of Olivia.
15. Essentially, the conference officer said he did not know who to believe as far as who was
getting physical custody of Olivia at what times - or at a minimum, he did not want to take
a position as to who he believed the primary custodian of Olivia was.
16. By making false and material misrepresentations to the conference officer, Lisa Milligan
altered the existing physical custody arrangement of Olivia which she and Geoffrey Dunkle
had put into effect on their own and which was in effect for well over a year.
17. Altering the physical custody arrangement of Olivia has not been in the best interests of
Olivia.
18. By making false and material misrepresentations to the conference officer, Lisa Milligan
gained an unfair but significant advantage in these custody proceedings.
19. Initially, after the conference, the undersigned waited for the conference summary to be
issued so the undersigned would be able to show the Court the conference summary "side
by side" with the daycare records so the Court could see for itself the misrepresentations
made by Lisa Milligan.
20. Geoffrey Dunkle can wait no longer to request relief from the Court and must file this
petition without having the conference summary in his possession.
21. In addition to the issue of returning Olivia to the physical custody arrangement she had
prior to the May 16, 2007 custody conference, there is the issue of where Olivia will go to
school starting in late August of this year.
22. From 2005 to the May 16, 2007 custody conference, who had physical custody of Olivia
can be described as follows:
i. Generally, starting in year 2005 and ending Tuesday, September 5, 2006,
Geoffrey Dunkle had physical custody of Olivia every Sunday, starting late
afternoon or early evening, through Thursday during the day. Geoffrey Dunkle
would also have physical custody every other weekend - the weekend being
Friday and Saturday night.
ii. From Wednesday, September 6, 2006 through and including Wednesday,
October 18, 2006, Geoffrey Dunkle had physical custody of Olivia every
Sunday, starting late afternoon or early evening, through Wednesday during the
day. Geoffrey Dunkle would also have physical custody every other weekend -
the weekend being Friday and Saturday night.
iii. From Thursday, October 19, 2006, up until the time of the Thursday, May 16,
2007 custody conference, Geoffrey Dunkle had physical custody of Olivia every
Sunday, starting late afternoon or early evening, through at least Thursday during
the day and usually through Friday during the day. During this time period
(Thursday, October 19, 2006 to Thursday, May 16, 2007), Geoffrey Dunkle also
had physical custody of Olivia every other weekend, such that when Olivia spent
Thursday nights with Geoffrey Dunkle and the weekend with Geoffrey Dunkle,
there was no interruption of time when Geoffrey Dunkle had physical custody of
Olivia.
WHEREFORE, Geoffrey Dunkle requests the Court:
1. Schedule an emergency hearing for the purpose of allowing Geoffrey
Dunkle to show the Court the material misrepresentations Lisa Milligan
made to the custody conference officer;
2. Order that the parties return to the primary physical custody schedule
which existed prior to the May 16, 2007 custody conference, pending
further hearing and/or Order of Court;
3. To make a determination where Olivia will go to school later this year;
and
4. Direct that Attorney Mangan issue to the Court his conference summary
report prior to the emergency hearing scheduled in this matter.
YOFFE & YOFFE, P.C.
r
sy
N. YOFF QUIRE
Attorney for Geoffrey Dunkle
214 Senate Avenue, Suite 404
Camp Hill, PA 17011
(717) 975-1838
Attorney ID No. 52933
jyoffe@verizon. net
LISA MILLIGAN,
Plaintiff
Vs.
GEOFFREY DUNKLE,
Defendant
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
: PENNSYLVANIA
NO. 07-2311
CIVIL ACTION
CUSTODY
VERIFICATION
I hereby state that I am an adult individual who is authorized to make this verification
and that the facts set forth in the foregoing Petition are true to the best of my knowledge,
information, and belief. I understand that false statements herein are made subject to the penalties
of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities.
Dated: 7 13 ??
G FREY DUNKLE
LISA MILLIGAN,
VS.
Plaintiff
GEOFFREY DUNKLE,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. 07-2311
CIVIL ACTION
CUSTODY
CERTIFICATE OF SERVICE
The undersigned certifies that on the date indicated below he served the attached Petition
for Special Relief on the individuals listed below. Service was made by e-mailing the same at
the e-mail address indicated.
John J. Mangan, Jr., Esq.
jmangan@earthlink.net
Jeanne B. Costopoulos, Esq.
jbclegal@aol.com
YOFFE & YOFFE, P.C.
Date: July 14, 2007 By
Y N. YOFFE, ESQUIRE
Attorney for Geoffrey Dunkle
214 Senate Avenue, Suite 404
Camp Hill, PA 17011
(717) 975-1838
Attorney ID No. 52933
jyoffe@verizon.net
;•- ? ? -n
-r, <-- t--- ?
O G -? ±?
_
f C,J ',?
._....
-
7
JUL 17 2007 q/
LISA MILLIGAN, ; IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY,
: PENNSYLVANIA
VS.
NO. 07-2311
GEOFFREY DUNKLE,
Defendant CIVIL ACTION
CUSTODY
ORDER
AND NOW, this day of 4-q 6u'-' , 2007, in consideration of the
Petition for Special Relief filed by Geoffrey Dunkle, it is hereby Ordered that a hearing on said
Petition is scheduled for the /0"-'* day of , 2007 at oZ ' ?d
avr:/p.m. in Courtroom # in the Cumberland County Courthouse,
"t, V7":- te,` J u 4.. CJ;'ld
BY THE COURT
,C
o?
>- co
LtJ !
[_L
LL G1
C-i
62
AUG 0 6 2007 $
LISA MILLIGAN,
VS.
Plaintiff
GEOFFREY DUNKLE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 07-2311 Civil Term
: ACTION IN CUSTODY
COURT ORDER
AND NOW, this day of August, 2007, upon consideration of the attached
Custody Conciliation Report, it is ordered and directed that:
1. This Order is entered pursuant to a Cstody Conciliation Conference. A Custody
Hearing is hereby scheduled on / day of l6&F-&, 2007 at
arn/im in Courtroom number _'? in the Cumberland County Court of
Common Pleas, Carlisle, PA 17013.
2. The Mother, Lisa Milligan and the Father, Geoffrey Dunkle, shall enjoy shared
legal custody of Olivia Dunkle, born February 17, 2002. The parties agree that
major non-emergency decisions concerning the child's health, welfare, education
and religion shall be made by them jointly, after discussion and consultation with
the other, with a view toward obtaining and following a harmoniously policy in
the child's best interest.
3. The Mother and Father shall share physical custody of the Olivia Dunkle on a
week on/week off basis from Sunday 1:00 pm through Sunday 1:00 pm.
4. Transportation: The non-custodial parent shall pick up and transport Olivia
unless the parties mutually agree to some alternative.
5. Mother and Father shall employ appropriate car seats/restraints for the Child
during transportation.
6. Telephone contact between Olivia Dunkle and the non-custodial parent shall be
liberal as agreed upon between the parties.
7. In the event that the custodial party is in need of a babysitter for a weekend, the
custodial parent shall contact the non-custodial parent and offer said babysitting
opportunity to the non-custodial parent.
8. Mother and Father shall not engage in any disparaging language with the Child
that would negatively affect the Child's love and affection for the other parent.
9. Father shall have Memorial Day and Mother shall have the Fourth of July with
Olivia, the times to be agreed upon by the parties.
10. In the event of a medical emergency, the custodial parent shall notify the other
parent as soon as practicable after the emergency is handled.
BY THE COURT,
J.
Distribution:
e B. Costopoulos, Esc
tey N. Yoffe, Esq.
J. Mangan, Esq.
J
LISA MILLIGAN,
Plaintiff
VS.
GEOFFREY DUNKLE,
Defendant/Petitioner
THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 07-2311
CIVIL ACTION - AT LAW
CUSTODY
INTERIM ORDER OF COURT
AND NOW, this day of g w. , 2007, following a brief hearing, it is
hereby Ordered that, pending the hearing currently scheduled on October 18, 2007, the child shall
attend kindergarten in the Cumberland Valley School District.
All remaining provisions of this court's prior order dated August 7, 2007 shall remain in full
force and effect.
Distribution:
/-,,= B. Costopoulos, Esquire
erey N. Yoffe, Esquire
V
BY THE COURT:
P4 ???
99t
LISA MILLIGAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. CIVIL ACTION - LAW
NO. 07-2311 CIVIL
GEOFFREY DUNKLE,
Defendant
ORDER
AND NOW, this / 14 day of October, 2007, after hearing, it is ordered and directed
that:
1. LEGAL CUSTODY
A. The parties shall have shared legal custody of Olivia Dunkle, born February 17,
2002. Shared legal custody means the right of both parents to control and to
share in making decisions of importance in the life of their child, including
education, medical, and religious decisions. Both parents shall be entitled to
equal access to the child's school, medical, dental and other important records.
B. As soon as practical after the receipt by a party, copies of the child's school
schedules, special events notifications, report cards, and similar items shall be
provided to the other party. Each shall notify the other party of any medical,
dental, optical and other appointments of the child with health care providers
sufficiently in advance thereof so that the other party can attend.
C. Notwithstanding that both parents share legal custody, non-major decisions
involving the child's day-to-day living shall be made by the parent then having
custody, consistent with the other provisions of this agreement.
y ?, J
9S •L A zZ 100 LOOZ
AdV1GI:iii E.Oc"d 3HI J0
NO. 07-2311 CIVIL
2. PHYSICAL CUSTODY
A. Physical custody: Primary physical custody of Olivia, as that term is defined
in the Custody Act, shall be shared on a week on/week off basis from Sunday
at 1:00 p.m. through Sunday at 1:00 p.m.
3. HOLIDAYS
The parties shall share custody of the child on major holidays as follows:
A. Easter: Father shall have custody of the child in all odd-numbered years and
Mother shall have custody in all even-numbered years on Easter Day from
9:00 a.m. until 7:00 p.m.
B. Memorial Day: Father shall have custody of the child in all odd-numbered
years and Mother shall have custody in all even-numbered years from Memorial
Day Eve at 1:00 p.m. until Memorial Day at 7:00 p.m.
C. Jubilee Day: Mother shall have custody of the child in all even-numbered years
and Father shall have custody in all odd-numbered years on Jubilee Day from
9:00 a.m. until 7:00 p.m.
D. Independence Day: The Independence Day holiday shall run from July 3Td at
7:00 a.m. until July 5th at 9:00 a.m. Mother shall have custody of the child
over the Independence Day holiday in odd-numbered years and Father shall
have custody in even-numbered years.
E. Labor Day: Father shall have custody of the child in all odd-numbered
years and Mother shall have custody in all even-numbered years from Labor
Day Eve at 1:00 p.m. until Labor Day at 7:00 p.m.
2
NO. 07-2311 CIVIL
F. Trick or Treat Night: Father shall have the child on the evening set as Trick
or Treat night in his local neighborhood from 5:00 p.m. until 9:00 p.m. Mother
shall have the child on the evening set as Trick or Treat night in her local
neighborhood from 5:00 p.m. until 9:00 p.m. In the event that Trick or Treat
night is on the same date in both Mother and Father's respective neighborhoods,
then Mother shall have custody in all odd-numbered years and Father shall
have custody in all even-numbered years on the evening designated as his or
her neighborhood's Trick or Treat night from 5:00 p.m. until 9:00 p.m.
G. Thanksgiving: Mother shall have custody of the child in all odd-numbered
years and Father shall have custody in all even-numbered years from
Thanksgiving Eve at 7:00 p.m. until Thanksgiving Day at 7:00 p.m.
H. Christmas: Father shall have custody of the child in all odd-numbered
years and Mother shall have custody in all even-numbered years from
Christmas Eve at 4:00 p.m. until Christmas Day at 12:00 noon. Mother shall
have custody of the child in all odd-numbered years and Father shall have
custody in all even-numbered years from Christmas Day at 12:00 noon until
the day after Christmas at 7:00 p.m.
1. Mother's Day/Father's Day: Mother shall have custody of the child every
Mother's Day and Father shall have custody of the child every Father's Day
from 9:00 a.m. until 7:00 p.m.
J. The holiday schedule shall supersede and take precedence over the regular
custody schedule.
3
0
NO. 07-2311 CIVIL
4. TRANSPORTATION
The non-custodial parent shall pick up and transport Olivia unless the
parties mutually agree to some alternative.
5. TELEPHONE CALLS
Telephone contact between Olivia and the non-custodial parent shall be
liberal as agreed upon between the parties.
6. DISPARAGING REMARKS
Each of the parties and any third party in the presence of Olivia shall take all
measures deemed advisable to foster a feeling of affection between Olivia and
the other parent. Neither party shall do, nor shall either parent permit any
third person to do, or say anything which may estrange Olivia from the other
parent, their spouse or relatives, or injure Olivia's opinion of the other party
or which may hamper the free and natural development of Olivia's love and
respect for the other parent. Neither parent shall initiate any comment or
discussion with Olivia regarding custody or support or other issues between
the parties without the consent of the other parent.
7. MODIFICATION OF ORDER
The parties agree to make reasonable efforts to accommodate their schedules.
They may modify custody at any time if such modification is mutually agreed
upon. If no mutual agreement can be reached, then both parties will strictly
adhere to the terms of this Order. Any modifications to this Order will be
interpreted as temporary and will not act as a permanent waiver unless
4
NO. 07-2311 CIVIL
executed in writing with the same force and effect as this Order.
BY THE COURT,
Jeanne Costopoulos
For the Plaintiff
Jeffrey Yoffe, Esquire
For the Defendant
Am
?a i'?s m